11.10 (b) The ability to generate accurate and complete copies of records in
both human readable and electronic form suitable for inspection, review, and
copying by the agency. Persons should contact the agency if there are any questions
regarding the ability of the agency to perform such review and copying of the
electronic records.

Comprehensive reports and all raw data can be made available
for inspection in human-readable format.

11.10(c) Protection of records to enable their accurate and ready retrieval
throughout the records retention period.

All data records are stored in protected storage in write-
and modification- protected files. Only authenticated users can retrieve data.

11.10 (d) Limiting system access to authorized individuals.

“Chrom&Spec” implements reliable authentication
system, based on recognized cryptographic algorithms (MD5 hashing with salt
values and AES encryption). “Chrom&Spec” defines several access levels for
users to control access to different software functions.

11.10 (e) Use of secure, computer-generated, time-stamped audit trails to
independently record the date and time of operator entries and actions that
create, modify, or delete electronic records. Record changes shall not obscure
previously recorded information. Such audit trail documentation shall be retained
for a period at least as long as that required for the subject electronic records
and shall be available for agency review and copying.

“Chrom&Spec” ensures that record changes cannot obscure
previously recorded information. All versions of data files are kept; there is no
overwriting of information.

11.10 (f) Use of operational system checks to enforce permitted sequencing of
steps and events, as appropriate.

“Chrom&Spec” uses system checks to validate user inputs and
implements wizards to guide users through permitted sequences of steps.

11.10 (g) Use of authority checks to ensure that only authorized individuals can
use the system, electronically sign a record, access the operation or computer system
input or output device, alter a record, or perform the operation at hand.

“Chrom&Spec” security subsystem, based on recognized cryptographic
algorithms (MD5 hashing with salt values and strong AES encryption) ensures that only
authorized individuals can use the system. User access to particular software functions
(including electronic signing of data records, altering records, managing of user records)
is controlled by administrators with “access level” technology, implemented in the
software.

11.10 (h) Use of device (e.g., terminal) checks to determine, as appropriate, the
validity of the source of data input or operational instruction.

Full integration of “Chrom&Spec” with particular equipment and
devices allows performing all necessary checks.

11.10 (i) Determination that persons who develop, maintain, or use electronic
record/electronic signature systems have the education, training, and experience
to perform their assigned tasks.

All employees in Ampersand Ltd. have adequate education and work
experience. Records of the education and employment history of Ampersand Ltd. employees
can be made available during audit of Ampersand Ltd.

11.10 (j) The establishment of, and adherence to, written policies that
hold individuals accountable and responsible for actions initiated under their
electronic signatures, in order to deter record and signature falsification.

It is the responsibility of the organization, which implements
and uses electronic signatures, to define policies.

11.10 (k) Use of appropriate controls over systems documentation including:
(1) Adequate controls over the distribution of, access to, and use of documentation
for system operation and maintenance. (2) Revision and change control procedures to
maintain an audit trail that documents time-sequenced development and modification of
systems documentation

(k)(1) This item is the responsibility of the end-user. (k)(2)
All modifications in “Chrom&Spec” development are documented, time stamped and audit trailed in Ampersand's version-control system.

§ 11.50 Signature manifestations.

11.50(a) Signed electronic records shall contain information associated with the signing
that clearly indicates all of the following: (1) The printed name of the signer; (2) The
date and time when the signature was executed; and (3) The meaning (such as review,
approval, responsibility, or authorship) associated with the signature.

“Chrom&Spec” electronic records contain the name of the signer,
date and time when the signature was executed, and the meaning associated with the
signature.

Both machine-readable data and human-readable screen and paper
reports contain the name of the signer, date and time when the signature was executed,
and the meaning associated with the signature.

§ 11.70 Signature/record linking

Electronic signatures and handwritten signatures executed to
electronic records shall be linked to their respective electronic records to ensure
that the signatures cannot be excised, copied, or otherwise transferred to falsify
an electronic record by ordinary means.

Electronic signatures and handwritten signatures executed to electronic records
shall be linked to their respective electronic records to ensure that the signatures
cannot be excised, copied, or otherwise transferred to falsify an electronic record
by ordinary means.

“Chrom&Spec” ensures that certificates, automatically
generated by the software, are unique to one individual.

“Chrom&Spec” also supports secured exporting and importing
of user certificates issued by other Certification Authorities. In such a case, the
Certification Authority must ensure that each electronic signature is unique to one
individual and cannot be reused by, or reassigned to, anyone else.

(b) Before an organization establishes, assigns, certifies, or otherwise sanctions
an individual’s electronic signature, or any element of such electronic signature,
the organization shall verify the identity of the individual.

This is a responsibility of the customer organization to
verify the identity of the individual.

(c) Persons using electronic signatures shall, prior to or at the time of such
use, certify to the agency that the electronic signatures in their system, used on
or after August 20, 1997, are intended to be the legally binding equivalent of
traditional handwritten signatures. (1) The certification shall be submitted in
paper form and signed with a traditional handwritten signature, to the Office of
Regional Operations (HFC–100), 5600 Fishers Lane, Rockville, MD 20857. (2) Persons
using electronic signatures shall, upon agency request, provide additional
certification or testimony that a specific electronic signature is the legally
binding equivalent of the signer’s handwritten signature.

This is a responsibility of the customer organization
and of the persons using electronic signatures.

§ 11.200 Electronic signature components and controls.

(a) Electronic signatures that are not based upon biometrics shall: (1) Employ
at least two distinct identification components such as an identification code
and password. (i) When an individual executes a series of signings during a
single, continuous period of controlled system access, the first signing shall
be executed using all electronic signature components; subsequent signings
shall be executed using at least one electronic signature component that is
only executable by, and designed to be used only by, the individual. (ii)
When an individual executes one or more signings not performed during a single,
continuous period of controlled system access, each signing shall be executed
using all of the electronic signature components. (2) Be used only by their
genuine owners; and (3) Be administered and executed to ensure that attempted
use of an individual’s electronic signature by anyone other than its genuine
owner requires collaboration of two or more individuals.

(a)(2) “Chrom&Spec” encrypts certificates and private
keys with strong AES algorithm to ensure that only the certificate owner can use
it. Encryption key is derived from user password with salt values and is never
stored in any files. It makes it impossible to copy, transfer or falsify somehow
user’s electronic signature.

(a)(3) In order to use an electronic signature user must
specify login name and password. Initial password for the user is assigned by
administrator. During first login user is prompted to change his password, so
the combination login name /password is known to the individual only. Only the
individual himself is allowed to change his password afterwards.

(b) Electronic signatures based upon biometrics shall be designed to ensure that
they cannot be used by anyone other than their genuine owners.

There are no electronic signatures based upon biometrics
in “Chrom&Spec”.

§ 11.300 Controls for identification codes/ passwords.

(a) Maintaining the uniqueness of each combined identification code and password,
such that no two individuals have the same combination of identification code and
password.

“Chrom&Spec” maintains uniqueness of user login names.

(b) Ensuring that identification code and password issuances are periodically
checked, recalled, or revised (e.g., to cover such events as password aging).

With “Chrom&Spec” administrators can configure identification
code and password periodic check and revision, including password aging.

(c) Following loss management procedures to electronically deauthorize lost, stolen,
missing, or otherwise potentially compromised tokens, cards, and other devices that
bear or generate identification code or password information, and to issue temporary
or permanent replacements using suitable, rigorous controls.

With “Chrom&Spec” administrators can at any time disable or enable
user accounts and create new user accounts.

(d) Use of transaction safeguards to prevent unauthorized use of passwords and/or
identification codes, and to detect and report in an immediate and urgent manner
any attempts at their unauthorized use to the system security unit, and, as appropriate,
to organizational management.

In “Chrom&Spec” only the user himself knows his password.
Software uses recognized MD5 one-way hashing with salt values to validate user
password and to ensure that no one can restore a password by analyzing any records
or files, created by “Chrom&Spec”.

“Chrom&Spec” can be configured in such a way that unauthorized
access attempts automatically disable user account and corresponding notification is
placed in system audit trail.

(e) Initial and periodic testing of devices, such as tokens or cards, that bear
or generate identification code or password information to ensure that they function
properly and have not been altered in an unauthorized manner.